OFAC - Venezuela General License 12 - Authorizing Certain Activities Necessary to Wind Down Operations or Existing Contracts with Petróleos de Venezuela, S.A. (PdVSA)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (614 words)

Notes:

*This is one of a handful of GLs that were active as of the date of the blocking of the Government of Venezuela (GOV) that were not amended to account for that fact. This is because it was expired when the GOV was blocked.

1) Venezuela 12 expired in April, 2019, with no further GLs issued to cover the activity within its scope.

2) Consult the Research System for GLs involving the scope of "wind down" general licenses, and compare Venezuela GL 11, which permits "maintenance" of operations; a concept broader than "wind down."

3) With respect to subsection (b), see Venezuela GL 7 - Authorizing Certain Activities Involving PDV Holding, Inc. and CITGO Holding, Inc.

4) Read in conjunction with Venezuela GLs 7-13, all of...

Welcome!

Welcome!

Venezuela General License 12 - Authorizing Certain Activities Necessary to Wind Down Operations or Existing Contracts with Petróleos de Venezuela, S.A. (PdVSA) (Expired)

TURBOFAC Commentary (614 words)